United States Office of Personnel Management 

The Federal Government's Human Resources Agency

Benefits Administration Letter

Number: 22-101 Date: March 15, 2022 

Subject: Changes to Acceptable Signature 

Requirements on Retirement Processing Forms

The Office of Personnel Management (OPM) previously published guidance 

through Benefits Administration Letter (BAL) 20-102, Temporary Changes to 

Retirement Application Processing While Operating Under Coronavirus 

Disease (COVID-19) Telework Policies. 

The purpose of this BAL is to outline the new changes to the signature 

requirements for retirement package forms. This BAL supersedes the 

temporary signature requirements outlined on BAL 20-102. In order to 

support the health and safety of individuals and to give Human Resource and 

Payroll Offices maximum flexibilities to submit retirement applications in a 

timely manner, OPM will allow the use of electronic signatures (including 

those that use digital signatures) on all retirement application forms. 

These changes are made in accordance with section 850.106 of title 5, Code 

of Federal Regulations , which allows electronic signatures on forms related 

to federal retirement and benefit programs. Agencies and Payroll offices are 

encouraged to implement the new changes effective on the date of 

publication of this BAL. Forms submitted in accordance with this BAL will be 

accepted as valid, and no additional documentation will be required. If the 

requirements for valid electronic signatures are not met, agencies will be 

expected to resubmit documentation that meet the new requirements. 
Benefits Administration Letter 22-101

2 

Permanent Changes to Acceptable Signature Requirements 

on Retirement Processing Forms

Under our new policy, OPM will accept electronic signatures on applications, 

documents, and forms OPM receives to adjudicate retirement and death in 

service claims. OPM will consider these electronic signatures as effective for 

purposes of processing, as long as the electronic signatures meet the 

requirements listed below. 

Going forward OPM will accept electronic signatures (including use of digital 

signatures) for the retirement forms listed in Appendix A. This includes 

signatures by applicants, Human Resources personnel, Payroll offices, 

witnesses, or other third parties (as applicable), along with any other 

required supporting documentation when the retirement forms require 

signatures of these parties. 

This list of forms is not intended to be all-inclusive; other post-retirement 

forms and documents may also be electronically signed and submitted as 

required by OPM’s retirement services. 

Types of Acceptable Electronic Signatures

OPM will now accept a wide range of electronic signatures (including use of 

digital signatures) on retirement forms. Acceptable electronic signature 

methods include the following: 

1. Electronic signed in accordance with 15 U.S.C. §§ 7001, 7021, and

7031 (please see the requirements listed below) submitted by

agencies. Agencies must keep the associated record that reflects the

process by which the signatures were created;

2. Personal Identity Verification (PIV) or Common Access Cards (CAC) or

other verifiable certificate authenticated signatures (ex. PDF

documents signed using a digital certificate);

3. Signatures created through a third-party software, such as DocuSign,

HelloSign, Adobe Sign, or other agency approved third-party software.

The digital signatures created must be verifiable certificate
Benefits Administration Letter 22-101

3 

authenticated signature and comply with 15 U.S.C. §§ 7001, 7021, 

and 7031. Agencies must keep the associated record that reflects the 

process by which the signatures were created;

Appendix B provides examples of electronic and digital signatures that will 

be accepted. We will continue to assess the risk of fraud, error, or misuse of 

the various types of acceptable electronic signatures and will make future 

updates to these acceptable methods as necessary. 

Requirements for Valid Electronic Signatures

In accordance with 15 U.S.C. §§ 7001, 7021, and 7031 on facilitating the 

use of electronic records and signatures, OPM will consider an electronic 

signature valid if it meets the following requirements: 

1. Intent to sign – Electronic signatures, like traditional wet ink

signatures, are valid only if each party intended to sign the

document.

2. Consent to do business electronically – All parties signing the

document agree to conduct the transaction using electronic means.

This consent may be express or implied in that all parties agree that

the electronic signatures appearing on the document are the same as

“wet” signatures for the purposes of validity, enforceability, and

admissibility.

3. Association of signature with the record –To qualify as an

electronic signature under 15 U.S.C. §§ 7001, 7021, and 7031, the

system used to capture the electronic signature must keep an

associated record that reflects the process by which the signature

was created, or generate a textual or graphic statement (which is

added to the signed record) proving that it was executed with an

electronic signature. This is done when the electronic signature is

time stamped on the electronic document at the time it is signed and

is saved as part of a PDF document.

4. Record retention – The law also requires that electronic signature

records be capable of retention and accurate reproduction for
Benefits Administration Letter 22-101

4 

reference by all parties or persons entitled to keep the record. OPM 

recommends that agency Chief Human Capital Officers (CHCO) 

review their records retention schedules for retirement application 

forms in accordance with the National Archives and Records 

Administration guidelines and the standards of OPM’s Guide to 

Personnel Recordkeeping. OPM’s Retirement Services maintains any 

federal employee record that could be used for retirement for 115 

years. 

To ensure documents with electronic signatures are created in a valid 

and secure manner, an agency should:

• Create and maintain documentation of the systems used to create the

records that contain electronic signatures.

• Ensure the records that include electronic signatures are created and

kept in a secure environment that protects the records from

unauthorized modification or destruction.

• Implement standard operating procedures for the creation, use, and

management of records that contain electronic signatures, and keep

adequate written documentation of those procedures.

• Create and keep records according to these documented standard

operating procedures.

• Outline steps to validate an electronic signature in the standard

operating procedures.

• Train agency personnel in the established standard operating

procedures.

Agencies will still be required to maintain and submit retirement packages in 

accordance with applicable Federal law on records management, including 5 

C.F.R. § 293.103, 36 C.F.R. § 1234, and the Business Records Act (BRA).

OPM recognizes that agency employees who are responsible for submitting 

and certifying retirement applications will have to work with their IT 

departments to make sure that all validation and storage requirements are 

met for the acceptable electronic signatures/digital signatures outlined in 
Benefits Administration Letter 22-101

5 

this BAL. It is imperative that agencies only submit electronic 

signatures/digital signatures to OPM that they can validate and that are 

being properly stored. OPM may need proof of agency verification and 

storage for any litigation that may arise in any retirement application or 

associated form.

Agencies should also ensure that the digital signature technologies and 

methods they adopt are compliant with Federal disability access 

requirements. Agency staff should be trained to use any of the accessibility 

features embedded in agency software and should be capable of assisting 

Federal employees with disabilities on how to submit a digitally signed 

document and application.

Agencies should continue to follow the electronic submission requirements 

outlined on BAL 12-102. This BAL does not supersede BAL 12-102. 

The Federal Employees’ Group Life Insurance (FEGLI) 

Forms

FEGLI forms must be processed in accordance with BAL 22-203, Changes to 

Acceptable Signature Requirements for Federal Employees’ Group Life 

Insurance (FEGLI) forms, which provides guidance to agencies on methods 

to sign, certify and process most commonly used FEGLI forms. This includes, 

but is not limited to, the SF 2821 (Agency Certification of Insurance Status) 

and SF 2823 (Designation of Beneficiary). 

For questions related to the guidance outlined on this BAL, please contact 

the Benefits Officer Development & Outreach group at benefits@opm.gov or 

call (202) 606-0788.
Benefits Administration Letter 22-101

6 

Sincerely,

Margaret Pearson

Associate Director

Retirement Services 

3 Encls.: 

1 Appendix A, Acceptable Forms with Electronic/Digital Signatures 

2 Appendix B, Examples of Acceptable Electronic/Digital Signatures

3 Common questions concerning Permanent Changes to Acceptable 

Signature Requirements on Retirement Processing Forms
Appendix A - Acceptable Forms with Electronic Signatures from 

Agencies and Payroll Officesi

Forms Certified by Agency Representatives Only

Form 

Number/Name

Number of 

Required 

Signatures

Agency 

and/or 

Payroll Office 

Signature

Other 

Signature 

(i.e., Notary, 

Financial 

Institution)

Special Requirements

SF 2806-1, Notice of 

Correction of Individual 

Retirement Record 

1 x 

Sent to OPM from 

Payroll Provider

SF 2810, FEHB Notice of 

Change in Health Benefits 

Enrollment 

1 x 

SF 2821, Agency 

Certification of Insurance 

Status (FEGLI) 

2 x 

There is no requirement 

that a certifying official 

cannot provide a 

facsimile signature

SF 3100, FERS Individual 

Retirement Record x 

No signature slot, 

normally stamped and 

sent electronically

Notification to OPM of 

Reemployment of 

Annuitant 

1 x 

Form must be 

completed and 

submitted to OPM 

according to the 

guidance on BAL 19-107

Notification to OPM of 

Separation of a 

Reemployed Annuitant - 

No Benefits Payable

1 x 

Form must be 

completed and 

submitted to OPM 

according to the 

guidance on BAL 19-107

RI 20-81, Request for 

Additional Information 1 x For OPM use only

RI 20-89, Verification of 

Military Retired Pay Status 1 x 

For OPM use only; form 

must be signed by 

Military Service 

retirement payroll 

providers
Form 

Number/Name

Number of 

Required 

Signatures

Agency 

and/or 

Payroll Office 

Signature

Other 

Signature 

(i.e., Notary, 

Financial 

Institution)

Special Requirements

RI 20-124, Certification of 

Service Performed as a Law 

Enforcement Officer, 

Firefighter, Nuclear 

Materials Courier, customs 

and Border Protection 

Officer (535 Service), or Air 

Traffic Controller

1 x 

Agencies must 

complete this form 

whenever an employee, 

who has performed 

service in one of these 

special provision 

categories, separates 

from the agency for any 

reason, including 

resignation, transfer, 

retirement (including 

disability retirement), 

and death

RI 38-133, Certification for 

Title 38 Physicians and 

Dentists of the Department 

of Veterans Affairs

1 x 

Only used for 

information on 

individuals receiving 

Special Pay under 

Chapter 74 of Title 38, 

U.S. Code

RI 79-08, Health Benefits 

Information Request 1 x For OPM use only

Forms Certified by both Applicants and Agency Representatives

Form 

Number/Name

Number of 

Required 

Signatures

Applicant

Signature

Agency 

and/or 

Payroll 

Office

Signature

Other 

Signature 

(i.e., Notary, 

Financial 

Institution)

Special 

Requirements

SF 2800A, CSRS 

Documentation and 

Elections in Support 

of Application for 

Death Benefits 

2 x x 
Form 

Number/Name

Number of 

Required 

Signatures

Applicant

Signature

Agency 

and/or 

Payroll 

Office

Signature

Other 

Signature 

(i.e., Notary, 

Financial 

Institution)

Special 

Requirements

SF 2801, CSRS 

Application for 

Immediate 

Retirement 

3 - 6 x x x 

The Spouse’s 

Consent to Survivor 

Election section of 

this form must be 

notarized and 

signed by the 

applicant's spouse 

when applicable; 

applicants may use 

remote/electronic 

notariesii

SF 2802, CSRS 

Application for 

Refund of 

Retirement 

Deductions 

2 - 4 x x x 

Certification from 

financial institution 

is required if 

rollover is elected; 

spouse/former 

spouse and witness 

signatures are 

required

SF 2804, CSRS 

Application to Make 

Voluntary 

Contributions

2 x x 

SF 2805, Request for 

Recovery of Debt 

Due to the United 

States 

2 x x 

SF 2809, FEHB 

Health Benefits 

Election Form

2 x x 

For Active Federal 

Employees only

SF 2817, Life 

Insurance Election 

(FEGLI)

2 x x 
Form 

Number/Name

Number of 

Required 

Signatures

Applicant 

Signature

Agency 

and/or 

Payroll 

Office 

Signature

Other 

Signature 

(i.e., Notary, 

Financial 

Institution)

Special 

Requirements

SF 2823, 

Designation of 

Beneficiary (FEGLI)

4 x x x 

Applicant may have 

two individuals 

witness their 

signature through a 

virtual 

environment; 

agency personnel 

may witness the 

execution of 

the SF 2823 as 

long as they are 

not named as 

beneficiaries

SF 3102, CSRS and 

FERS Designation of 

Beneficiary 

4 x x x 

Applicant may have 

two individuals 

witness their 

signature through a 

virtual 

environment; 

agency personnel 

may witness the 

execution of the SF 

3102 as long as 

they are not named 

as beneficiaries

SF 3104B, FERS 

Documentation and 

Elections in Support 

of Application for 

Death Benefits 

2 - 3 x x x 

Certification from 

financial institution 

is required if 

rollover is elected 

SF 3106, FERS 

Application for 

Refund of 

Retirement 

Deductions 

2 - 4 x x x 

Certification from 

financial institution 

is required if 

rollover is elected; 

spouse/former 

spouse and witness 

signatures are 

required
Form 

Number/Name

Number of 

Required 

Signatures

Applicant 

Signature

Agency 

and/or 

Payroll 

Office 

Signature

Other 

Signature 

(i.e., Notary, 

Financial 

Institution)

Special 

Requirements

SF 3107, FERS 

Application for 

Immediate 

Retirement 

3 - 6 x x 

The Spouse’s 

Consent to Survivor 

Election section of 

this form must be 

notarized and 

signed by the 

applicant's spouse 

when applicableapplicants may use 

remote/electronic 

notariesii

SF 3108, FERS 

Application to Make 

Service Credit 

Payment

3 x x

SF 3112, 

Documentation in 

Support of Disability 

Retirement 

Application 

3 x x x 

SF 3116, Phased 

Employment, 

Phased Retirement 

Status

2 x x 

FE-6 DEP, Statement 

of Claim, Option C 

(FEGLI)

2 x x 

Please see BAL 22-

203 for special 

submission 

requirements
List of Forms Certified by Applicants Only

Form 

Number/Name

Number of 

Required 

Signatures

Applicant 

Signature

Other 

Signature (i.e.,

Notary, Financial 

Institution)

Special Requirements

SF 2800, CSRS Application 

for Death Benefits 1 x 

SF 2818, Continuation of 

Life Insurance Coverage as 

an Annuitant or 

Compensationer (FEGLI)

1 x 

SF 2819, Notification of 

Conversion Privilege 

(FEGLI)

2 x x 

Please see BAL 22-203 for 

special submission 

requirements

SF 3104, FERS Application 

for Death Benefits 1 x 

RI 10-125, Federal 

Employee Retirement 

Coverage Corrections Act 

(FERCCA) Election Form

1 x 

RI 16-28, Authorization for 

Direct Payments 1 x 

RI 20-07, Representative 

Payee Application 2 x x 

Additional documentation 

may be necessary as 

required by RI 30-3,

Information Necessary for 

a Competency 

Determination 

RI 20-63, Survivor Annuity 

Election for a Spouse 1 x 

RI 20-64, Survivor Annuity 

Election for a Former 

Spouse 

2 x x 

Instructions for this form 

can be found on RI 20-

64B, Information on 

Electing a Survivor 

Annuity for Your Former 

Spouse (CSRS)
Form 

Number/Name

Number of 

Required 

Signatures

Applicant 

Signature

Other 

Signature (i.e., 

Notary, Financial 

Institution)

Special Requirements

RI 20-64A, Former Spouse 

Survivor Annuity Election 2 x x 

This form must be 

notarized and signed by 

the applicant's current 

spouse if retiree is 

married

RI 20-84, Civilian Deposit 

Election Letter 1 x For OPM use only

RI 20-97, Estimated 

Earnings During Military 

Service

1 x 

RI 25-14, Self-Certification 

of Full-Time School 

Attendance 

1 x 

RI 25-41, Initial 

Certification of Full-Time 

School Attendance 

1 x 

 

 

RI 25-51, CSRS Survivor 

Annuitant Express Pay 

Application for Death 

Benefits 

1 x 

 

 

RI 76-10, Assignment of 

Life Insurance (FEGLI) 3 x x 

Applicant may have two 

individuals witness their 

signature through a 

virtual environment; 

agency personnel may 

witness the execution of 

the RI 76-10 as long as 

they are not named as 

assignees

RI 76-15, Election to 

Convert Option C - Family 

Life Insurance

1 x For OPM use only

RI 79-9, Health Benefits

Cancellation or Suspension 2 x 

Confirmation

RI 92-19, Application for 

Deferred or Postponed 

Retirement 

1 - 4 x x 

Schedule A of this 

application must be 

notarized and signed by 

the applicant's spouse if 

applicable; applicants 

may use 

remote/electronic 

notariesii
Form 

Number/Name

Number of 

Required 

Signatures

Applicant 

Signature

Other 

Signature (i.e., 

Notary, Financial 

Institution)

Special Requirements

RI 92-25, Final Action for 

FERS Deposit and/or 

Redeposit Payment 

Election 

4 x For OPM use only

RI 94-07, Death Benefit 

Payment Rollover Election 3 x x 

For OPM use only; 

certification from financial 

institution is required if 

rollover is elected 

RI 98-07, Social Security 

Disability Benefits 

Information Request 

1 x 

 

For OPM use only

 

 

 

FE-6, Claim for Death 

Benefits (FEGLI) 1 x 

Please see BAL 22-203 for 

special submission 

requirements

OPM 1496, CSRS 

Application for Deferred 

Retirement

1 - 5 x x 

For separations before 

October 1, 1956, only; 

schedule B of this form 

must be notarized and 

signed by the applicant's 

spouse if applicable; 

applicants may use 

remote/electronic 

notariesii

OPM 1496A, CSRS 

Application for Deferred 

Retirement

1 - 4 x x 

For separations on or 

after October 1, 1956, 

only; schedule B of this 

form must be notarized 

and signed by the 

applicant's spouse if 

applicable; applicants 

may use 

remote/electronic 

notariesii

OPM 2809, Health Benefits 

Election Form 2 x x 

For annuitants, survivor 

annuitants, former 

spouses, or children and 

former spouses who are 

eligible for temporary 

continuation of coverage 

(TCC) use only; certified 

by OPM
i For more information on the Office of Management and Budget’s Regulatory Review of forms, please visit The Office of Information 

and Regulatory Affairs’ website. ii Applicants may use remote/electronic notaries. Visit The National Notary Association's website for more information and guidance on 

remote online notarization.
Appendix B - Examples of Acceptable Electronic/

Digital Signatures

Example #1 

Electronic Signatures on documents submitted by agencies: 

Example #2 

Forms signed using a verifiable digital signing certificates (ex. Personal 

Identity Verification (PIV), Common Access Cards (CAC), other digital 

certificate technologies): 
Example #3

Electronic Signatures through a third-party digital certificate-base signing 

software: 
Common questions concerning Permanent Changes to 

Acceptable Signature Requirements on Retirement 

Processing Forms

1. What does OPM mean by allowing “electronic” and “digital”

signatures on retirement processing forms?

OPM will now accept forms and documents included in a retiree’s

retirement package to be electronically or digitally signed. The term

“digital signature” means a signature that has been created by software

that contains an authentication certificate and includes the individual’s

name, date and time of signature. Examples of these types of software

include Adobe Acrobat or DocuSign. The term “electronic signature”

means electronic forms/documents that contain a “wet” or digital

signature, that is made into a photocopy, converted to a PDF or other

type of electronic document, and then submitted to OPM. The two

terms—i.e., “digital signature” and “electronic signature”—may be used

interchangeably throughout this BAL and in accordance with 5 C.F.R. §

850.106.

2. Is everyone required to submit retirement forms containing

electronic signatures?

No, employees and agency personnel including Payroll offices, may still

submit original retirement forms, including but not limited to the forms

listed on Appendix A, containing valid signatures or photocopies of signed

documents directly from an official system of records in the custody of

the agency according to the procedures listed on BAL 12-102.

3. When should employees sign the forms electronically?

Employees are not required to sign retirement forms electronically.

Signing the forms with electronic or digital signatures is optional;

applicants may use this option only when they are not able to sign the

documents with a “wet,” “pen-and-ink” or handwritten physical

signature. Agencies are encouraged to create procedures that outline

when employees should use “wet” signatures on forms/documents. The
procedures should follow protocols from the Safer Federal Workforce 

Task Force’s guidance on keeping employees and agencies operating 

safely during the COVID-19 pandemic. 

4. How can employees and agencies sign the forms

electronically/digitally?

Most OPM retirement forms are Adobe Acrobat fillable forms and may be

completed and signed by PIV/CAC authentication. Other types of thirdparty software used to complete the forms or documents will dictate the

electronic/digital signature method used to sign the form. Regardless of

the method used, the electronic record must be tamper-proof once it is

electronically signed in accordance with 15 U.S.C. §§ 7001, 7021, and

7031. The most common methods used to capture an electronic signature

include:

o A handwritten signature input on a display screen using a stylus

device

o A digitized image of a handwritten signature that is attached to an

electronic record

o A PIV/ CAC authenticated digital signature.

5. What if the form I want to submit with an electronic or digital

signature is not listed on Appendix A?

Employees should contact their Agency’s benefits office to inquire about

whether a particular form not listed on Appendix A can be submitted using

an electronic or digital signature. Benefits offices should contact their

Headquarters level Benefits Officers for additional guidance. Agency

Benefits Officers are encouraged to contact their assigned OPM liaison for

guidance on submitting specific forms or documents not referenced or

listed on this BAL.
6. Can retirement forms/documents containing electronic/digital

signatures be submitted through alternate methods besides

regular mail or the Secure Drop Box (i.e., text message)?

No. At this time, OPM has not established an alternate process to accept

such forms/documents through any other submission method. Agencies

should continue to follow the existing process to report the death of a

Federal employee or submit reemployed annuitant and Phased

Employment/Phased Retirement notifications.

7. How do Agencies ensure they are following 15 U.S.C. §§ 7001,

7021, and 7031 in facilitating the use of electronic records and

signatures?

The head of each agency must establish internal guidelines and

procedures to accept and validate electronic signatures on retirement

and benefit forms. Agencies should use adequate IT systems that can

properly maintain documents that contain electronic signatures and

ensure the records are created and kept in a secure environment that

protects the records from unauthorized modification or destruction.

8. How does this BAL differ from OPM’s recent guidance on changes

to retirement application processing while operating under

COVID-19?

This BAL expands the flexibility to submit retirement application forms

with electronic signatures including the FERS/CSRS Designation of

Beneficiary (SF 3102 and SF 2808), the SF 2823, Designation of

Beneficiary (FEGLI), and the SF 2818, Continuation of Life Insurance

Coverage (FEGLI). This BAL also adds the flexibility for electronic

signatures to be created through a third-party software, such as

DocuSign, HelloSign, Adobe Sign, or other agency approved third-party

software. Additionally, this BAL removes the requirement for payroll

offices to use OPM’s secure electronic drop box to upload scanned

retirement packages. The secure drop box has been disabled and can no

longer be used to submit retirement documents.
9. Can a current or former federal employee submit an electronically

signed document to OPM’s Retirement Services without going

through their agency?

No, this BAL requires that all electronically signed forms must be

validated and stored by the employing agency. Retirement Services does

not currently accept digital signatures directly from employees, former

employees, annuitants, or their survivors.